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Federal Tax Controversy & Litigation

Century-Old Law Next-Generation Strategy

Coverstone Law serves as a federal tax controversy attorney for individuals, partnerships, and businesses involved in high-stakes disputes with the IRS. Our expertise includes navigating IRS audits and providing expert witness preparation for tax court, ensuring that clients receive the best representation possible. We also leverage innovative strategies, including the use of AI in tax practice, to support CPAs and maximize outcomes in complex tax matters.

Our Practice

What We Do

Coverstone Law is a federal tax controversy attorney specializing in high-stakes federal tax disputes and litigation. We handle complex tax matters such as Tax Court trials, IRS audits, and BBA partnership audits, along with expert-witness work that is crucial for high-dollar cases. Our approach combines trial-ready litigation discipline with innovative technology tools, including AI in tax practice, that many tax lawyers have yet to adopt.

FEDERAL TAX DISPUTES

We manage audits, IRS appeals, and U.S. Tax Court litigation for individuals, partnerships, and closely held businesses. Our expertise extends to substantiation cases through intricate partnership adjustments.

EXPERT WITNESS CONSULTING & STRATEGY

As a tax attorney for CPAs, we identify the right expert for each issue, develop tailored expert strategies, coordinate report preparation, and prepare witnesses for direct and cross-examination at trial. We have successfully handled six Tax Court trials since 2022.

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For Advisors

Most of our federal tax matters come through referring advisors. If you're a CPA, EA, wealth manager, financial or business advisor, or family office principal with a client facing an IRS audit, an IRS notice, or a partnership adjustment and you want a second opinion, we handle those conversations directly. Our expertise as a federal tax controversy attorney allows us to navigate these complex situations effectively. We work regularly under IRC § 7525, welcome co-counsel arrangements on Tax Court matters, and provide resources such as the F.I.R.M. framework to our referral network. Additionally, our tax attorney for CPAs can assist with tax court expert witness preparation to ensure your clients receive the best support possible.

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Additional Services

In addition to addressing federal tax controversy with the expertise of a federal tax controversy attorney, we offer comprehensive estate planning and related business services for our existing tax clients and their families.

ESTATE PLANNING AND PROBATE

Our services include wills, revocable and irrevocable trusts, powers of attorney, and healthcare directives, with a specific focus on the planning needs that may arise from a tax controversy matter, especially during an IRS audit.

BUSINESS FORMATION

We assist in entity formation, developing operating and shareholder agreements, and ensuring tax-aware structuring for new and existing businesses owned by our current firm clients, including tax attorney for CPAs who require expert witness preparation for tax court.

Meet Mike

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Michael B. Coverstone

Mike represents individuals, partnerships, and closely held businesses in their highest-stakes moments with the IRS — complex audits, administrative appeals, U.S. Tax Court litigation, BBA partnership matters, and multi-million-dollar disputes where a generalist tax attorney isn't enough.

Mike has been counsel on more than 80 U.S. Tax Court cases. Since 2022, he has prepared expert reports and expert witnesses for six Tax Court trials — the kind of work that decides high-dollar cases. His litigation background covers the full range of federal tax controversies, from substantiation matters to complex partnership disputes involving real estate investments and syndications.

Mike's practice pairs trial-ready litigation strategy with the tools most tax lawyers haven't adopted yet. He is the author of the F.I.R.M. Framework for Responsible AI Use in Federal Tax Practice, a published set of safeguards used by tax counsel, CPAs, and EAs working federal tax matters.

Before moving to Sarasota in 2020, Mike practiced in Atlanta and began his legal career as an IP litigation paralegal at Wilmer Cutler Pickering Hale and Dorr (WilmerHale) in Washington, D.C. He is admitted to practice in Florida, Georgia, and before the United States Tax Court.

Mike has been recognized in Best Lawyers: Ones to Watch in America in 2022 (Tax Law) and in 2023–2026 (Tax Law and Tax Litigation and Controversy). He lives in Sarasota with his wife Lucy and their two daughters, Margaret and Caroline.

Past results do not guarantee similar outcomes. Every federal tax matter turns on its own facts.

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Of Counsel at Kostelanetz LLP

Mike is also Counsel at Kostelanetz LLP, a New York–based firm widely recognized as one of the country's leading tax controversy boutiques, specializing in areas such as IRS audits and providing services as a federal tax controversy attorney. Coverstone Law clients benefit from the strategic depth of a national firm, leveraging ai in tax practice, while retaining the direct attorney relationship typical of a local Florida practice, including expert witness preparation for tax court and tailored support for CPAs seeking a knowledgeable tax attorney.

Mike's Kostelanetz, LLP Profile

Federal Tax Controversy & Litigation · Based in Sarasota, Florida, our firm practices nationally as a federal tax controversy attorney. We also specialize in IRS audit representation and provide expert witness preparation for tax court cases. Additionally, we utilize AI in tax practice to enhance our services.

This website serves as attorney advertising, prepared by Coverstone Law, PLLC, Sarasota, FL. Michael B. Coverstone, Esq. is responsible for its content. The information on this website is for general informational purposes only and does not constitute legal advice or create an attorney-client relationship. You are not considered a client of the firm, and no communication with the firm is protected by the attorney-client privilege until an engagement letter has been signed. Past results do not guarantee similar outcomes. Every federal tax matter turns on its own facts, and we also offer services tailored for CPAs seeking a tax attorney.